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NY J87947





August 25, 2003

CLA-2-84:RR:NC:1:110 J87947

CATEGORY: CLASSIFICATION

TARIFF NO.: 8473.30.5000

Ms. Leslie J. Cummings
Vice President of Finance & Treasurer
Knape & Vogt Manufacturing Company
2700 Oak Industrial Drive NE
Grand Rapids, MI 49505-6083

RE: The tariff classification of a gel palm support from Taiwan.

Dear Ms. Cummings:

In your letter dated August 4, 2003 you requested a tariff classification ruling.

The merchandise under consideration is the “Gel Palm Support” also known as a wrist rest. Two individual wrist rests will be imported to be permanently attached to Knape & Vogt Manufacturing computer keyboard trays by means of three screw inserts. The full-length gel palm supports comfortably mold to each user’s palm providing relief from hand and wrist fatigue while working on a keyboard. Gel palm support number 1825 measures approximately 18 inches long by 2¼ inches wide and is approximately ¾ inch thick. Gel palm support number 1524 measures approximately 24 inches long by 2¼ inches wide and is approximately ¾ inch thick. Both gel palm supports are constructed of silicon diffused polyurethane gel with a neoprene foam backed fabric mounted onto a hardboard substrate. The gel palm supports are not sold separately; they are imported for the sole purpose of installing onto the keyboard trays manufactured for Knape & Vogt Manufacturing Company.

From the information provided with your ruling request, the silicon diffused polyurethane gel appears to be the dominant substance used in the construction of this item providing its essential character. The Explanatory Notes (ENs) of the Harmonized Tariff System (HTS) provide guidance in the interpretation of the Harmonized Commodity Description and Coding System at the international level. The gel palm support wrist wrests are designed and principally used with ADP (Automatic Data Processing) input units such as keyboards, and meets the definition of an “accessory” as outlined in the ENs to Heading 8473 of the HTS.

The applicable subheading for both Gel Palm Supports (product numbers 1524 and 1825) will be 8473.30.5000, Harmonized Tariff Schedule of the United States (HTS), which provides for “Parts and accessoriesmachines of headings 8469 to 8472: Parts and accessories of the machines of heading 8471: Not incorporating a cathode ray tube: Other.” The general rate of duty will be free.

This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 C.F.R. 177).

A copy of the ruling or the control number indicated above should be provided with the entry documents filed at the time this merchandise is imported. If you have any questions regarding the ruling, contact National Import Specialist Eileen S. Kaplan at 646-733-3016.

Sincerely,

Robert B. Swierupski
Director,

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